Canada: New tax proposal increases uncertainty for SMEs
A new federal tax proposal was announced on 18th of July 2017 by the Finance Minister and it could have a chance of uncertain consequences for small businesses and enterprises (SMEs). The Canadian Federation of Independent Business (CFIB) has
See MoreHong Kong: Government plans to introduce tax relief for small and medium enterprises
Following a question regarding two tax measures proposed by Chief Executive in her election manifesto, the Secretary for Financial Services and the Treasury has replied on focusing tax relief for small and medium enterprises. In the 2017-18 Budget,
See MoreJapan: amendments to CFC rules in 2017 tax reform
The 2017 tax reform bills were passed by the 193rd ordinary session of the Japanese National Diet on 27 March 2017. Accordingly, the Japanese regulations on controlled foreign companies (CFC) have been fundamentally revised, taking into account the
See MoreCyprus: Taxpayers must submit a temporary tax return before 31st July
All companies that are Cyprus tax residents and taxed in accordance with the Cyprus Income Tax Laws and Regulations are required to submit a temporary tax return Form T.D.6 by 31 July 2017. Temporary tax for 2017 is payable in two equal
See MoreArgentina: New Regulations ‘General Resolution 4094-E’ enters into force
The Federal Tax Authority (FTA), on July 18, 2017, published the General Resolution 4094-E on the Official Gazette. This Resolution had been introduced into income tax in 2013. The time when the 2013 tax reform abolished the capital gains tax
See MoreIndia: Physical presence in the source state is not necessary to constitute a service PE
A recent decision of the Bengaluru Bench of the Income-tax Appellate Tribunal (Tribunal) in the case of: ABB FZ-LLC v. DCIT [ITA(TP) No. 1103/Bang/2013, assessed the India-UAE (United Arab Emirates) Double Taxation Avoidance Agreement (tax treaty)
See MoreNetherlands: The Dutch government publishes consultation on anti-tax avoidance directive
The State Secretary of Finance provided a letter to Dutch parliament in which he indicated that an internet consultation has been opened for a draft bill on 10th July 2017. The draft bill has been formulating in order to implement the first EU
See MoreOECD updates guidance on country by country reporting
On 20 July 2017 the OECD published updates to the guidance on country by country (CbC) reporting requirements under Action 13 of the project on base erosion and profit shifting (BEPS). This guidance for tax administrations and multinational groups
See MoreItaly: Tax ruling on withholding tax exemption for foreign investments in real estate
The Tax Authority of Italy (Agenzia delle Entrate) has issued a tax ruling -Risoluzione n. 78/2017- on 27 June 2017. The ruling is related to certain foreign investment funds which wish to benefit from an exemption from withholding tax. The tax
See MoreThailand: Consultation process of the draft Transfer Pricing rules
The Revenue Department of Thailand is requesting public comments with respect to the Draft Transfer Pricing Rules which were approved by the Thai Cabinet on May 2015. The comments are to be provided by 7 July 2017. Recently, the draft measures were
See MoreBrazil: Tax authority issues a ruling on tax rates for reinsurers
The tax authority of Brazil has issued COSIT Consultation Response no. 62/2017 (Solução de Consulta n. 62/2017) setting out views of the General Office to Coordinate Taxation (COSIT) on tax rates applicable to reinsurers. The Consultation
See MoreKorea: Recent developments on corporate taxation
With the aim of encouraging the development of new growth-engine industries, reinforcing employment-friendly tax schemes, and facilitating corporate restructuring, a few amendments that affect foreign investment or foreign invested companies have
See MoreEstonia: key changes to corporate income tax rules enacted
The Estonian Minister of Finance submitted the Bill on Amendments to the Income Tax Act (the bill) for consultation on 17 April 2017, which was approved by the Parliament on 19 June 2017. Significant changes in the Income Tax Act include a reduced
See MoreVietnam: National Assembly passes the new technology transfer law
The National Assembly of Vietnam on 19 June 2017 approved the Law on Technology Transfer No. 07/2017 / QH14 ("LTT 2017"). The new law (LTT 2017) comes into force on 1 July 2018 and replaces the Law on Technology Transfer No. 80/2006 / QH11 of 29
See MoreIMF deputy managing director comments on tax and economic growth in Asia
On 12 July 2017 the IMF Deputy Managing Director Mitsuhiro Furusawa, speaking in Indonesia, commented on the importance of international tax developments for economic growth in Asia. He stressed the importance of revenue mobilization and
See MoreFinland: Tax administration publishes guidance on the allocation of profits to PEs
On 13 June 2017, the Tax Administration published guidance on the allocation of profits to a permanent establishment (PE). A permanent establishment in Finland is liable to Finnish taxation on profits arising in Finland. Permanent establishment
See MoreFrance: Planning to remove CICE Tax Credit
With the aim of creating a more business friendly environment, the French Government is planning to remove the competitiveness and employment (CICE) tax credit and reduce social security contributions. As an approach on this, the CICE tax credit
See MoreRomania: Planning progressive Income Tax
The Government of Romania is planning to replace the flat tax on corporate income with a tax on turnover and this could be effective as early as 2018. The company revenues in Romania are currently taxed at a rate of 16%, but this could be replaced
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